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Section 68: Revenue Fails to Prove Unexplained Share Application Money; Additions Must Be More Than Suspicion.

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Full Text of the Document

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....Addition u/s 68 - share application money/share capital and share premium as unexplained - The onus was on revenue to dislodge assessee’s documentary evidences and rebut the same by bringing on record any cogent material to demonstrate that assessee’s own money flew back in the shape of share application / share premium - nothing of that sort has been brought on record by Ld. AO. It is trite law that no additions could be made merely on the basis of suspicion, conjectures or surmises - AT....